Arencibia Privacy Policy

1. Introduction

Who are we?

Arencibia Inc. is a company incorporated in Pennsylvania at 1161 Richland Commerce Drive, Quakertown, PA USA. Affiliates of Arencibia Inc. include Arencibia HoldCo, LLC, Arencibia Holdings, LLC, and Arencibia International, LLC, all of which are limited liability companies incorporated in Delaware. These entities (together, “Arencibia”, “we”, “us” or “our”) may decide the means and purpose of processing personal data, in which case they are a “controller” of that data.

What’s this policy about?

Arencibia is an industry leader in the monitoring, analysis and recovery of industrial gases. Arencibia partners with the global manufacturing industry to recycle industrial gases and deliver tremendous financial and environmental benefits.

Arencibia operates its gas recovery systems through a software-as-a-service platform known as the MARS Platform. The website located at Arencibia.com and related domains and subdomains, describe these services (collectively referred to as "Services").

This policy explains how we process your personal data as a data controller when you use, or contact us about, our Services.

What about changes?

We update this policy from time to time so please check back in. If we make significant changes, we may notify you by email by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law. In certain cases, we may also seek your consent to further use of your Personal Information where this is required.

Minors (children)

We welcome all persons to contact us on our website. However, applicable laws may restrict our ability to collect personal information from minors unless we have first obtained the consent of the minor's parent or guardian.

If you are under 18 and want to submit a contact form to us, please ask your parent or guardian to submit it for you. Arencibia does not otherwise knowingly collect Personal Information of minors, and the Services are not directed to minors. If we become aware that we have collected personal information from a minor in conflict with applicable law, we will delete that information or obtain the requisite consent from the minor's parent or guardian.

How do you contact us? (if you have questions about this policy or to exercise your rights)

Attn: Privacy Team

Arencibia Inc.
1161 Richland Commerce Drive
Quakertown, PA 18951
United States of America

info@Arencibia.com

We try to respond to legitimate requests as soon as reasonably possible and within 30 days of your request. Occasionally, it takes us longer. In such circumstances we will notify you of the delay, give you a reason for that delay, and continue to update you regarding the progress of our response.

What are your rights?

You have the following rights in respect of personal data, although these rights may be limited in some circumstances:

• Ask us to send a copy of your data to you or someone else
• Ask us to restrict, stop processing, or delete your data
• Object to our processing of your data
• Object to use of your personal data for direct marketing
• Ask us to correct inaccuracies

If we rely on consent to process data, or send direct marketing, you can withdraw consent by sending an email to info@Arencibia.com.

The California Privacy Rights Act (“CPRA”) may also apply to California residents and households. These rights include the right to: (i) know what Personal Information is being collected about them, (ii) know whether their personal information is sold or shared and to whom, (iii) Opt Out and say no to the sale or sharing of Personal Information, (iv) access their personal information, and (v) equal service and price, even if they exercise their privacy rights.

2. Your Personal Data and How We Use It

Enquiry data

(information we receive when you get in touch) including:

• Name
• Contact details, email, phone, email address
• Other personal data you send to us as part of enquiries.

How we use it

We process this information to respond to your support and other enquiries.

Legal basis

We may process this data in accordance with the terms of our contract with you (where we need this information to provide Services to you) or to take steps at your request prior to entering a contract.

We also use this to pursue our legitimate interests, including: (a) our interest in responding to enquiries to ensure smooth operation of our business and services; and (b) to understand customers and improve our Services, by taking on-board your feedback.

More information

You may be required to provide us with certain information for us to respond to your enquiries.

Sources and recipients

Sources: We collect this information from you with your consent when you send it to us.

Recipients include:

• Formspree
• AWS
• Google
• Copper CRM
• Slack

Account Data

We process the following personal data relating to customers if they set up an account with us:

• your username, password, email address, if provided;
• your profile name, if provided;
• telephone number, if provided; and
• language and location (IP location);
• the use you make of our Services and the content you provide while doing so.

How we use it

We process this information in order to enable you to register for, log into, access, use, and pay for our Services, and to enforce our terms.

Legal basis

We process this personal data in accordance with the terms of our contract with you (where we need this information to provide Services to you) or to take steps at your request prior to entering into a contract.

More information

You may be required to provide us with certain information to make full use of our Services.

Sources and recipients

Sources: We collect this information from you.

Recipients include:

• Formspree
• AWS
• Google
• Copper CRM
• Slack

Marketing/Messaging

We process the following information about you to send you emails or text messages to let you know about news, content and updates about to Arencibia and the Services:

• Name
• Company name, job title
• Contact information (such as email address or phone number)

How we use it

We process this information to send you promotional and non-promotional material about us and our Services (or to call you about our Services).

Legal basis

Unless we are contacting you as staff of a corporate entity, or where the “soft-opt-in” applies, we process your personal data for marketing with your consent.

If you are staff of a corporate entity, or if we have asked you for consent to send marketing material when negotiating your purchase of services, we may process this data in pursuit of legitimate interests in keeping you informed about our Services through marketing email and/or text messages or calls.

We may send messages to let you know about the status of Arencibia and/or the MARS Platform, changes to our supply chain, privacy and similar policies or other terms, either: (a) where necessary for us to comply with contractual obligations to you; or (b) in pursuit of our respective legitimate interests to ensure you receive prompt notice of important changes.

Sources & Recipients

Sources: We normally collect this information from you.

As part of our business-to-business marketing, we may collect personal data from third party sources to identify individuals who hold relevant job roles in key industries.

Recipients include:

• Formspree
• AWS
• Google
• Copper CRM
• Slack

Security

Arencibia takes reasonable and standard measures to protect the personal data we store, transmit, or otherwise process, against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. We regularly consider appropriate new security technology and methods as we maintain and develop our software and systems.

However, you should keep in mind that the Services are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. Please also be aware that despite our best efforts to ensure the security of your data, we cannot guarantee that your information will be 100% secure.

Please recognize that protecting your personal data is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, such as using a strong password, keeping your password secret, and using two-factor authentication. If you have reason to believe that the security of your account might have been compromised (for example, your password has been leaked), or if you suspect someone else is using your account, please let us know immediately.

Cookies

We (and the third-party service providers working on our behalf) use various technologies to collect personal information. This may include saving cookies to your device, using pixels and similar technologies.

Transfers

If you are located outside the United States and choose to provide personal data to us, we will transfer that data to (or receive it in) the United States and process it there. Your personal data may be transferred outside of your state, province, country, or other jurisdiction, where privacy laws may not be as protective as those in your jurisdiction. If we transfer personal data, we take all reasonable steps to ensure your privacy rights continue to be protected.

Where required by law (such as under the GDPR) if we transfer personal data to a country which does not provide an adequate level of protection, we implement appropriate safeguards, including standard contractual clauses approved by the competent authorities. For more information drop us a line using the contact details at the start of this policy.

Disclosure

Other than as set out above, we may use or disclose your personal data:

• Where required by law, government, competent authorities or the courts; or to establish, exercise or defend our legal rights; or for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies); or to take precautions against liability, protect rights, property or safety of Arencibia, our users, other individuals or the public; to maintain and protect security and integrity of our Services or infrastructure; to protect Arencibia and our Services from fraud, or abusive or unlawful use; or to investigate and defend Arencibia against third-party claims or allegations.
• Our policy is to provide notice of disclosures to law enforcement or public authorities, unless prohibited by law or court order (including orders under 18 U.S.C. § 2705(b)).
• Please note we share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling, and other similar purposes. In addition, our Services may contain links to other websites not controlled by us, and these other websites may reference or link to our Services; we encourage you to read the privacy policies applicable to these other websites.
• With members of our corporate group, our suppliers, and subcontractors, as necessary for the purposes set out in this policy (such suppliers may include payment providers, providers of hosting services, sales and marketing service providers, providers of document and content management tools, providers of analytic data services, and suppliers of other services such as system support, subscription services, verification and ticketing).

California Privacy Rights Act of 2020 (CPRA)

Pursuant to §§ 1798.110 and 1798.115 of the CPRA the categories of Personal Information we have collected about consumers and disclosed about consumers for a business purpose in the preceding 12 months may include:

• Identifiers such as a real name, alias, postal address, email address, unique personal or online identifier, Internet Protocol address, account name, SSN, driver's license or passport number, or other similar identifiers;
• Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including signature, bank account number, credit card number, debit card number, or any other financial information;
• Commercial information, including products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information, including, browsing history, search history, and information regarding a consumer's interaction with an internet website, or advertisement; and
• Professional or employment-related information.

Please note that not all of this information is collected or disclosed from all consumers using our Services.

WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING